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The LRN ethics and compliance risk management practices report

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Anonymous/Confidential Reporting Chann<br />

Ethics & Compliance Offic<br />

DETAILED RESULTS<br />

Legal Departme<br />

First Reporting Channel<br />

Internal Ombudsm<br />

After supervisors, 1 in 5 companies expects employees to <strong>report</strong> first using the % anonymous/<br />

Respondents<br />

confidential <strong>report</strong>ing channel. This result<br />

0%<br />

may 10% be linked 20% to why companies 30% <strong>report</strong> 40% that their 50%<br />

% Respondents<br />

two top challenges in detection are employee fear of retaliation <strong>and</strong> employees are not<br />

motivated to <strong>report</strong>.<br />

Supervisor 28%<br />

0% 10% 20% 30% 40% 50%<br />

Anonymous Reporting Channel<br />

Supervisor 28%<br />

Given that Ethics anonymous/confidential & Compliance Office 16% helplines are the second most common <strong>report</strong>ing<br />

17%<br />

channel, companies must sure they have qualified personnel to answer the lines <strong>and</strong> refer<br />

Human Resources 13%<br />

16%<br />

allegations to the appropriate function.<br />

Anonymous Reporting Channel<br />

Ethics & Compliance Office<br />

Legal Department<br />

Human Resources 13%<br />

No Set Policy<br />

Legal Department 11%<br />

Internal Ombudsman<br />

No Set Policy 9%<br />

17%<br />

11%<br />

9%<br />

Nearly 1 in 3 companies expects employees to <strong>report</strong> violations first to supervisors.<br />

9%<br />

Given that supervisors Don't are Know expected 4% to be a first line of detection, it is incumbent on<br />

9%<br />

companies to fully educate supervisors so they know how to h<strong>and</strong>le violation <strong>report</strong>s<br />

Don't Know 4%<br />

according to company policies. Again, this is also why involving managers in <strong>risk</strong> assessments<br />

is beneficial for companies, given their greater knowledge of potential gaps <strong>and</strong> high <strong>risk</strong><br />

employees who might cause <strong>ethics</strong> or <strong>compliance</strong> problems.<br />

Internal Ombudsman<br />

First Reporting Channel<br />

No set poli<br />

13. What are your biggest challenges in detecting <strong>ethics</strong> <strong>and</strong> <strong>compliance</strong> violations<br />

Employee fears of retaliation <strong>and</strong> lack of motivation lead the <strong>risk</strong> detection challenges.<br />

Top Challenges<br />

Anonymous/conf<br />

Top Challenges<br />

% Respondents<br />

0% 20% 40% 60% 80% 100%<br />

% Respondents<br />

Employees fear retaliation<br />

0% 20% 64% 40% 60% 80% 100%<br />

Compliance eth<br />

Employees not motivated<br />

Employees fear retaliation 64%<br />

Innapropriate uses<br />

Employees not motivated 54%<br />

Lack of formal <strong>management</strong> process<br />

Innapropriate uses 46%<br />

Employees don't underst<strong>and</strong><br />

Lack of formal <strong>management</strong> process 42%<br />

Insufficient staff to respond<br />

Employees don't underst<strong>and</strong> 33%<br />

Other<br />

Insufficient staff to respond 28%<br />

No significant challenges<br />

Other 19%<br />

54%<br />

46%<br />

42%<br />

33%<br />

28%<br />

19%<br />

13%<br />

No significant challenges<br />

13%<br />

Despite the prevalence of anonymous <strong>report</strong>ing channels, employees fear retaliation <strong>and</strong> lack<br />

the motivation to <strong>report</strong>. Companies cited detection as their main challenge in 2008. Nearly<br />

half of respondents indicate they have no significant problems in this area, while the other<br />

half cites a wide range of challenges that hamper their detection efforts. Topping the list,<br />

almost two-thirds companies believe their employees fear retaliation. Meanwhile, half the<br />

companies cite employee lack of motivation to <strong>report</strong> violations a significant factor.<br />

<strong>The</strong> irony of these statistics about fear of retaliation <strong>and</strong> employee apathy is that<br />

organizations increased their efforts to communicate, educate employees about <strong>ethics</strong> <strong>and</strong><br />

<strong>compliance</strong>, <strong>and</strong> ensure they have ready access to <strong>report</strong> violations. <strong>The</strong> survey results show<br />

that the nearly 9 out of 10 multinational companies offer at least three <strong>report</strong>ing methods<br />

for employees to use in their home region, <strong>and</strong> 7 out of 10 have at least three methods<br />

even in their international offices. Nearly all companies offer their workforce an anonymous<br />

or confidential channel to <strong>report</strong> <strong>ethics</strong> <strong>and</strong> <strong>compliance</strong> violations, <strong>and</strong> in 2 out of 10 of<br />

those enterprises, the company prefers the anonymous line to be its first line of <strong>report</strong>ing.<br />

In addition, 4 out of 10 companies also offer an internal ombudsman as a “go-to” person<br />

<strong>LRN</strong> | 2008 Ethics <strong>and</strong> Compliance Risk Management Practices Report | 33

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